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.� .., <br /> California Regional Water Quality Control Board1 , <br /> Central Valley Region <br /> s%d <br /> Steven T.Butler,Chair <br /> Winston H.Hickox Gray Davis <br /> Secretaryfor Sacramento Main Office Governor <br /> Environmental Internet Address: http://w .sw b.ca.gov/— gcb5 <br /> Protection 3443 Routier Road,Suite A,Sacramento,California 95827-3003R� <br /> Phone(916)255-3000•FAX(916)255.3015 yen <br /> 3 April 2003 APR 0 4 20033 <br /> Mr. R.M. Jones ENVIRONMENT HEALTH <br /> Woodbridge Partners Inc. PERMIT/SERVICES <br /> 639 East Lockeford St. <br /> Lodi, CA 95240 <br /> RECLAMATION PLANFOR CONVERSION OFLINED POND 1 TO A STORM WATER <br /> RETENTIONPOND, VICTOR FINE FOODS FACILITY, SAN JOAQUIN COUNTY(Case#1430) <br /> Central Valley Regional Water Control Board staff(staff)has reviewed your plan to clean out, repair, - <br /> and operate Pond 1 as a storm water retention pond. Staff has the following comments: <br /> 1. Title 27 Section 21400 allows two methods of closing Class II surface impoundments. Clean <br /> closure involves removing the liner components and any contaminated soil found beneath the <br /> impoundment. After a successful clean-closure the unit is no longer subject to Title 27 and the <br /> owner is free to use the site as he wishes. If it is found to be impracticable to clean close a unit it <br /> may be closed as a landfill. All residual wastes and liner materials must be removed or <br /> compacted, the excavation filled and covered with an engineered cover that complies with Title <br /> 27. Closure as a landfill may be less expensive in the short run but limits are placed on future <br /> land use and the owner incurs the expense of continued post closure monitoring and <br /> maintenance. You propose to repair and use the unit for storm water. The regulations do not <br /> provide a mechanism for converting a Class II unit to other uses, therefore until the unit is closed <br /> by one the two methods noted above it remains a Class 11 unit. As such the unit will be regulated <br /> and monitored under the requirements of Title 27. The maintenance and monitoring of an active <br /> Class II unit required by Title 27 would be an ongoing expense in excess of that expected for a <br /> conventional storm water pond. <br /> 2. The plan calls for removing disposing of all remaining liquids; removing, drying and disposing <br /> the estimated five to ten feet of solids in the pond; and rinsing the pond surface until clean. All <br /> leaks in the primary liner will be patched per industry standards. The plan for cleaning and <br /> restoring the primary liner is fine as far as it goes,before the pond is approved for discharge the <br /> primary liner must pass an electric leak test or equivalent test with no detectable leaks. <br /> 3. The plan requires that any obvious leaks in the secondary liner will be patched per industry <br /> standards. The plan should be revised to describe the actions that will be taken to detect leaks in <br /> the secondary liner. <br /> 4. The plan also calls for removing and disposing of all leachate from the LCRS; and the LCRS will <br /> be rinsed and the rinsate disposed of The plan should be revised to state that rinsing of the <br /> LCRS will continue until the rinsate test clean. <br /> California Environmental Protection Agency <br /> ea Recycled Paper <br />